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Where the original property is not still owned by the transferee at the transferor's death (see I7.381A for the significance of this), the relief may still be available in relation to property which represents it, as set out below.

First, there are provisions concerning shares owned by the transferee immediately before the transferor's death, or his own earlier death, which represent the property he acquired under the transfer. If they would under any of TCGA 1992, ss 126–136 (reorganisation of share capital etc) be identified with the original property or part of it, they are treated as if they were the original property and the transferee's period of ownership of the original property is treated as including his period of ownership of the shares¹.

Shares issued in consideration of the transfer of agricultural property consisting of the original property (or part of it) are treated in the same way². See Example 1 below. It is not entirely clear that these provisions are cumulative (ie that shares resulting from a reorganisation of shares